Justia Civil Rights Opinion Summaries

During a routine traffic stop, Houston Police Officer fatally shot John Allen, Jr. Plaintiffs brought over a dozen claims against Defendant, two other involved police officers, and the city. The individual defendants claim the benefit of qualified immunity. After years of litigation, the district court, in ruling on a motion to dismiss in response to Plaintiffs’ complaint, dismissed the claims in toto. Plaintiffs appealed the dismissal and requested reassignment to a different district judge.   The Fifth Circuit agreed with Plaintiffs that the dismissal of the Section 1983 claims against Defendant for excessive force, denial of medical care, and unlawful arrest was an error. The court reversed and remanded those claims. The court explained that taking as true that Defendant had no reason to believe Allen was armed and that Defendant knew Allen was seriously injured and likely could not move, a police officer would know, under these precedents, that to handcuff Allen was an arrest without probable cause under clearly established law. The court affirmed the dismissal of Plaintiffs’ remaining claims is affirmed. The court denied, as moot, Plaintiffs’ request for reassignment to a new judge. View "Allen v. Hays" on Justia Law

The Equal Employment Opportunity Commission (EEOC) sued Methodist Hospitals of Dallas (Methodist) for allegedly violating the Americans with Disabilities Act (ADA). The EEOC asserts that Methodist’s categorical policy of hiring the most qualified candidate violates the ADA when a qualified disabled employee requests reassignment to a vacant role, even if he or she is not the most qualified applicant. The EEOC also alleged that Methodist failed to reasonably accommodate a disabled employee, who was not reassigned to a vacant position for which she applied. The district court granted Methodist’s motion for summary judgment on both claims. The EEOC appealed, arguing that the Supreme Court’s ruling in US Airways, Inc. v. Barnett requires Methodist to make exceptions to its most-qualified-applicant policy and that the employee was entitled to a reasonable accommodation under the ADA.   The Fifth Circuit vacated the judgment of the district court as to Methodist’s most-qualified-applicant policy and remand for further proceedings consistent with this opinion. The court affirmed the judgment as to the EEOC’s reasonable accommodations claim involving the employee. The court explained that at summary judgment, an employee’s “unilateral withdrawal from the interactive process is fatal to her claim,” so long as the employer “engaged in a good-faith, interactive process with the employee regarding her request for a reasonable accommodation.” Based on the evidence, no reasonable jury could find that Methodist was unwilling to participate in the interactive process. When the employee did not respond to either the August 7th letter or the follow-up letter after her appeal of her termination, she caused the breakdown of the interactive process. Thus, Methodist did not act unlawfully. View "EEOC v. Methodist Hospitals" on Justia Law

Four police officers unlawfully arrested Plaintiff. Plaintiff sued under 42 U.S.C. Section 1983. The officers appeal the district court’s denial of their summary judgment motion as to (1) excessive force (Officer W.), (2) false arrest (all officers), and (3) fabrication of evidence (Officer L.).   The Fifth Circuit dismissed the appeal and held that it lacked jurisdiction. The court explained that Officer W. argued that Plaintiff took a defensive and threatening posture, resisted being pulled from the vehicle, struggled after being removed, and willfully and aggressively refused to follow commands while resisting the officer’s detainment. Contrary to Officer W.’s argument, those facts are of a genuine dispute. Officer W. failed to take the facts in a light most favorable to Plaintiff, instead relying on facts different from those assumed by the district court. Accordingly, the court wrote that it lacked jurisdiction to consider Officer W.’s appeal of the genuineness of the district court’s factual determinations.   Further, the court addressed the basis of our jurisdiction over Officer L.’s appeal, which does not invoke qualified immunity. Federal courts of appeal have jurisdiction over “appeals from all final decisions of the district courts.” Denial of summary judgment is not a final decision. Thus, the court explained that it lacked jurisdiction over Officer L.’s appeal of this claim. View "Ducksworth v. Landrum" on Justia Law

Plaintiff filed a lawsuit against Lewisville Independent School District (“LISD”) and seven school board members, alleging that the district’s at-large election system violated Section 2 of the Voting Rights Act (“VRA”) and seeking injunctive relief. The district court determined that Plaintiff lacked standing to bring his Section 2 claim because he is white. The district court then granted Defendants’ motion for sanctions against Plaintiff, his attorneys, and their law firm based on the findings that Plaintiff’s lawsuit was frivolous under 52 U.S.C. Section 10310(e) and his attorneys multiplied proceedings unreasonably and vexatiously under 28 U.S.C. Section 1927.   
The Fifth Circuit vacated the district court’s sanctions order and remanded to determine the extent to which the order is footed upon specific contemptuous conduct in the attorneys’ prosecution of the case. The court held that Plaintiff’s lawsuit did not merit sanctions. The court concluded that sanctions against Plaintiff were unwarranted because precedent in the circuit did not squarely foreclose his legal argument and because he sought to extend existing law. Critically, LISD points to no precedent in the circuit considering whether a voter in his position has standing under the VRA, let alone “squarely controlling precedent.” Further, as Plaintiff’s s lawsuit was not frivolous and relied on an “unsettled legal theory,”  his attorneys cannot be sanctioned under Section 1927 simply for filing the action. View "Vaughan v. Lewisville Indep Sch Dist" on Justia Law

After prevailing in state court on claims that he was fired in retaliation for exercising his state constitutional right to freedom of expression, Plaintiff filed a federal suit alleging the same set of facts but asserting for the first time a First Amendment claim. The district court dismissed Plaintiff’s suit, finding that Defendants’ factual attack showed that the only remedy not barred by sovereign immunity was impossible to grant and that Kling’s claim was prescribed. On appeal, Plaintiff contends that a factual attack on a district court’s subject matter jurisdiction is improper at the pleadings stage and that his state lawsuit interrupted prescription on his newly asserted federal claim because both rely on the same set of operative facts.   The Fifth Circuit concluded that the district court did not err in dismissing Plaintiff’s official capacity claims as barred by sovereign immunity and accordingly affirmed that ruling in the district court’s decision. However, because there are no clear controlling precedents from the Louisiana Supreme Court as to whether prescription on Plaintiff’s federal claim was interrupted by his state action, the court certified to that court to answer the following:In Louisiana, under what circumstances, if any, does the commencement of a suit in a court of competent jurisdiction and venue interrupt prescription as to causes of action, understood as legal claims rather than the facts giving rise to them, not asserted in that suit? View "Kling v. Hebert" on Justia Law

A man was shot and killed in his jewelry shop in 1983, and Decedent was sentenced to death for the crime. Thirty years later, Louisiana vacated Decedent’s conviction because new evidence identified the real murderer. After his release from prison, Decedent filed a Section 1983 suit seeking damages from police officers, prosecutors, and the local government for suppressing, fabricating, and destroying evidence. Decedent died shortly thereafter, leaving Plaintiff as the executrix of his estate. In 2021, the district court dismissed Plaintiff’s amended complaint in its entirety based on Fed. R. Civ. P. 12(b)(6) as to some defendants and 12(c) as to others.   The Fifth Circuit affirmed. The court explained that Plaintiff brought a traditional negligence claim. Louisiana uses the typical reasonable-person standard to assess an individual’s liability for negligence. For the same reasons that Plaintiff did not adequately plead constitutional violations due to the defendants’ suppression, fabrication, and destruction of evidence, she also fails to plead sufficient factual matter to show that they violated the standard of care of a reasonable officer. Accordingly, the court found that the district court thus properly dismissed this claim. View "Armstrong v. Ashley" on Justia Law

Plaintiff was detained beyond the expiration of his sentence. After his release, he sought redress for this violation of his rights by bringing a lawsuit against various Louisiana officials under 42 U.S.C. Section 1983 and Louisiana state law. The district court dismissed most of Plaintiff’s claims but allowed a supervisory liability claim against Department Secretary James LeBlanc to proceed by denying qualified immunity. Secretary LeBlanc appealed the denial of qualified immunity, arguing that his conduct wasn’t objectively unreasonable in light of clearly established law.   The Fifth Circuit reversed. The court reasoned that the right to timely release is clearly established. But Plaintiff failed to adequately brief—and has thus forfeited—any meritorious argument that Secretary LeBlanc’s behavior was objectively unreasonable in light of that right. The court explained that to the extent that Plaintiff argues the merits, it’s inadequately briefed. Plaintiff’s entire presentation on the issue of objective unreasonableness amounts to just this single conclusory statement: “It is inherently unreasonable for the secretary . . . to fail to enact policies and procedures to ensure the prompt release of inmates who have served their sentences in accordance to the law.” A single, unsupported sentence isn’t enough to adequately brief the issue. View "Taylor v. LeBlanc" on Justia Law

The decedent committed suicide in his cell. On behalf of her minor child, Plaintiff sued the warden at Ouachita Correctional Center (“OCC”) and the sheriff of Ouachita Parish in their official capacities; she also purports to have sued them in their individual capacities. All federal claims are brought under 42 U.S.C. Section 1983 for violations of the decedent’s Eighth Amendment rights. Plaintiff additionally sued under related state laws for negligence and vicarious liability. The district court granted summary judgment.   The Fifth Circuit affirmed. The court explained the warden cannot be sued in his official capacity. Official-capacity suits may be brought only against an official acting as a policymaker. Further, although the sheriff can be sued in his official capacity, those claims also fail. The Sheriff, as the final policymaker in the Parish, does satisfy the second requirement of the analysis and can be sued in his official capacity, assuming Plaintiff provides evidence that the conduct prong is met. However, Section 1983 does not allow recovery under a theory of respondeat superior; a plaintiff must show that the local government’s policy or custom violated the plaintiff’s constitutional rights. Moreover, the court explained that even if Plaintiff adequately pleaded her individual-capacity claims, she has not alleged a genuine dispute as to any material fact to hold defendants responsible under a supervisory-liability theory. View "Guillot v. Russell" on Justia Law

Plaintiff, proceeding pro se, filed a lawsuit in Texas state court against several officials at the Texas Department of Criminal Justice, where he remains an inmate. He alleged violations of his First and Eighth Amendment rights under 42 U.S.C. Section 1983 arising out of a housing transfer and subsequent physical altercation. According to Plaintiff, he had previously been sexually harassed and threatened by inmates in boot camp housing; after asking the sergeant for a transfer to the main building on account of the harassment and threats, he was assigned housing in the main building. Defendants removed the case to federal court, whereupon the district court granted their motion to dismiss all of Plaintiff's claims except for two: his First Amendment retaliation and Eighth Amendment failure-to-protect claims. The district court granted Defendant’s motion for summary judgment on qualified immunity grounds. The district court dismissed Plaintiff’s remaining claims with prejudice, and he appealed.   The Fifth Circuit reversed in part and affirmed the district court’s summary judgment dismissal of Plaintiff’s First Amendment retaliation claim. The court reasoned that the facts are consistent with Plaintiff’s allegation that Defendant transferred Plaintiff back to boot camp housing to teach him a lesson about seeking housing transfers from other officials, knowing that he faced a substantial risk of being assaulted by the inmates who he had previously reported to prison officials during the officer protection investigation. The court concluded that this statement is sufficient to create a genuine material factual dispute. However, the court did not decide whether, given this factual dispute, Defendant violated clearly established law. View "Luna v. Davis" on Justia Law

This case concerns attorney misconduct in the Court-Supervised Settlement Program established in the wake of the 2010 Deepwater Horizon oil rig disaster. Appellant, a Louisiana attorney representing oil spill claimants in the settlement program, was accused of funneling money to a settlement program staff attorney through improper referral payments. In a disciplinary proceeding, the en banc Eastern District of Louisiana found that Appellant’s actions violated the Louisiana Rules of Professional Conduct and suspended him from practicing law before the Eastern District of Louisiana for one year. Appellant appealed, arguing that the en banc court misapplied the Louisiana Rules of Professional Conduct and abused its discretion by imposing an excessive sanction.   The Fifth Circuit reversed the en banc court’s order suspending Appellant from the practice of law for one year each for violations of Rule 1.5(e) and 8.4(a). The court affirmed the en banc court’s holding that Appellant violated Rule 8.4(d). Finally, the court remanded to the en banc court for further proceedings, noting on remand, the court is free to impose on Appellant whatever sanction it sees fit for the 8.4(d) violation, including but not limited to its previous one-year suspension. The court explained that the en banc court misapplied Louisiana Rules of Professional Conduct Rule 1.5(e) and 8.4(a) but not Rule 8.4(d). Additionally, the en banc court did not abuse its discretion by imposing a one-year suspension on Appellant for his violation of 8.4(d). View "In re Jonathan Andry" on Justia Law